A Virginia circuit court ruled September 17, 2012 that e-mails generated by climate scientist Michael Mann when he worked at the University of Virginia were exempt from the state's Freedom of Information Act (FOIA).

Rarely does denial of a FOIA request appear to be a victory for open inquiry, but the Prince William County Circuit Court decision was greeted as such by defenders of climate science.

Mann, who put together the famous "hockey stick" graph of global temperature records and indicators, has been the target of repeated attacks by climate change deniers. The graph reconstructs the Earth's temperature over the last 1,000 years, showing a dramatic spike beginning with the Industrial Revolution. It is based on large amounts of data and has been confirmed in its general outlines by many other scientific studies. Mann, who now teaches at Penn State, was at U.Va. from 1999 to 2005.

Climate deniers' efforts to discredit Mann's work by digging up his private e-mails have not worked. He has been exonerated of any wrongdoing by multiple investigations. An effort by Virginia Attorney General Ken Cuccinelli to get access to more e-mails was rejected in 2012 by the Virginia Supreme Court.

The most recent case seeking Mann's e-mails was brought by the American Tradition Institute.